Gain is allocated to nonqualified use by multiplying it by a fraction, with the aggregate periods of nonqualified use as the numerator and the total period the taxpayer owned the property as the denominator.

When a tax exempt entity is acting like a business and competing with taxpaying business, UBIT applies to protect those tax-paying businesses from unfair competition.A ROBS plan would likely make more sense for that venture if the capital needs will be signification, i.e > about $80K. 

The rent is about $40 shy of the Mortgage (principal/interest/tax) payment, so I make up the difference out of pocket.

That is because there is a significant risk the taxpayer will redeem, and the tenant will have to move.

Apple just made a $38B tax payment in order to repatriate their cash held overseas.

However there could be a way for them to purchase a property using the 1031 exchange that they later convert to a primary residence in a few years when they fully retire.But there's a huge hurdle first and that is that the LLC is actually the tax payer for the property they are selling. 

So you are changing the taxpayer of the property right before a sale and 1031. 

The second is the small taxpayer safe harbor. 

I received several such inquiries during this past tax season (and the taxpayers were upfront about why they were asking).

You will need to register at REVENUE.TN.GOV for a TN business license and tax payment accounts.